In the case of Fontaine v. California in 1967, the U.S Supreme Court ruled on a matter concerning self-incrimination and police interrogation. The defendant, Mr. Fontaine, was arrested for burglary and during his detention he confessed to several other burglaries without being informed of his right to remain silent or have an attorney present - rights protected under the Fifth Amendment's protection against self-incrimination (Miranda Rights). His confessions were used as evidence in court leading to his conviction. However, this case reached the Supreme Court which held that since Mr.Fontaine had not been properly advised of his constitutional rights before questioning by law enforcement officers, any statements made by him could not be admitted into evidence at trial due to violation of Miranda Rights established earlier in 1966 through Miranda v Arizona ruling. Therefore, it reversed Fontaine’s conviction.

In the dissenting opinion for Fontaine v. California, Justice Harlan argued that the majority's decision to reverse and remand the case was based on an incorrect interpretation of Miranda v. Arizona. He contended that under Miranda, a suspect must be informed of their rights before questioning begins but does not require police to cease interrogation if a suspect indicates they wish to remain silent or consult with counsel after questioning has begun. In this case, he believed there was no violation because Fontaine had been properly advised of his rights prior to being questioned by police officers and voluntarily chose to waive those rights during subsequent interrogations without requesting legal counsel or expressing desire for silence. Therefore, according to Justice Harlan’s view, any statements made by Fontaine should have been admissible in court as evidence against him.